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UNITED STATES v. NATIONAL BANK OF SOUTH DAKOTA

No. 80-1008.

622 F.2d 365 (1980)

UNITED STATES of America and Donald E. Merrill, Revenue Agent of the Internal Revenue Service, Appellees, v. NATIONAL BANK OF SOUTH DAKOTA, B. H. Dail, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided May 20, 1980.

Attorney(s) appearing for the Case

B. H. Dail, Rapid City, S. D., filed brief pro se.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Charles E. Brookhart, Melvin E. Clark, Jr., Attys., Tax Div., Dept. of Justice, Washington, D. C., and Terry L. Pechota, U. S. Atty., Rapid City, S. D., filed brief for appellees.

Before HEANEY, ROSS and McMILLIAN, Circuit Judges.

PER CURIAM.

These are three IRS summons cases,1 consolidated in this appeal, in which an IRS agent sought and obtained enforcement of three IRS summonses from the same district court2 for the purposes of determining the income tax liability for 1976-1978 of taxpayer-intervenor, B. H. Dail.3,4 In his pro se appeal brief taxpayer (1) challenges the summonses...

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